In United States v. Carter, No. 18-14806 (Aug. 12,
2020) (Grant, William Pryor, Antoon), the Court upheld the defendant’s
ACCA sentence.
The issue was whether two prior Alabama drug offenses were
committed on separate occasions. Based
on a review of the indictment and plea admissions, the Court held that they were
more likely than not committed separately, because only one of the two offenses
received a location-based enhancement under state law.